DCT
8:25-cv-01546
BelAir Electronics Inc v. Goospery Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BelAir Electronics, Inc. (Illinois)
- Defendant: Goospery, Inc. (California)
- Plaintiff’s Counsel: Law Offices of Marc Libarle; Haller Law PLLC
- Case Identification: 8:25-cv-01546, C.D. Cal., 07/15/2025
- Venue Allegations: Venue is asserted on the basis that Defendant is a California corporation that resides in the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s extensive line of protective cases for mobile phones and tablets infringes three U.S. patents related to the structure of such protective "masks."
- Technical Context: The patents relate to protective coverings for mobile devices, a technology area that has evolved significantly alongside the underlying design of mobile phones, from early flip-phones to modern single-body smartphones.
- Key Procedural History: The complaint alleges that all three asserted patents have expired, meaning the litigation is focused exclusively on collecting past damages. Plaintiff alleges it provided Defendant with notice of the asserted patents and the likelihood of infringement via email correspondence beginning on July 24, 2024.
Case Timeline
| Date | Event |
|---|---|
| 2000-11-17 | Earliest Patent Priority Date (’291, ’195, ’676 Patents) |
| 2007-03-20 | U.S. Patent No. 7,194,291 Issues |
| 2011-05-10 | U.S. Patent No. 7,941,195 Issues |
| 2018-10-09 | U.S. Patent No. 10,097,676 Issues |
| 2021-10-23 | '676 Patent Expiration Date (as alleged in complaint) |
| 2022-11-16 | '291 & '195 Patent Expiration Date (as alleged in complaint) |
| 2024-07-24 | Plaintiff alleges first notice of infringement was sent to Defendant |
| 2025-07-15 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,194,291 - "Protective Mask of Mobile Phone"
- Patent Identification: U.S. Patent No. 7,194,291, “Protective Mask of Mobile Phone,” issued March 20, 2007 (’291 Patent). (Compl. ¶3).
The Invention Explained
- Problem Addressed: The patent’s background section states that early mobile phone housings were "very smooth and delicate," making them susceptible to abrasion and "ill-favored scars" from normal use, which diminished their quality and value. It also notes the user cost associated with replacing phones to keep up with changing fashions. (’291 Patent, col. 1:21-34).
- The Patented Solution: The invention is a removable, multi-part "protective mask" that sheathes the mobile phone. It consists of an "upper cover body" and a "lower cover body" that are molded to conform to the phone's front and rear housings, respectively. (’291 Patent, col. 2:19-22). The mask portions use "a plurality of flanges" that are "retained at the edge of the front phone housing" to couple the mask to the phone. (’291 Patent, col. 2:40-45; Fig. 3). This design aims to prevent abrasion while also allowing for customization through printed patterns. (’291 Patent, Abstract).
- Technical Importance: The invention provided a method for both protecting and stylistically customizing early-generation mobile phones, such as flip-phones, without requiring permanent modification or replacement of the device itself. (’291 Patent, col. 3:6-10).
Key Claims at a Glance
- The complaint asserts independent claims 1, 6, and 9. (Compl. ¶22).
- Independent Claim 1: A protective mask comprising:
- a first mask portion molded to conform to a first portion of a mobile phone's exterior housing;
- the first mask portion having flanges to couple and retain it to the housing;
- a second mask portion molded to conform to a second portion of the housing, adapted to be coupled and retained;
- wherein the first and second mask portions are retained to the exterior housing. (’291 Patent, col. 3:21-41).
- Independent Claim 6: Adds a limitation to Claim 1, requiring that the "first mask portion including an opening that is associated with an opening in the exterior housing to permit access to a feature of the mobile phone." (’291 Patent, col. 4:1-22).
- Independent Claim 9: Adds a further limitation, requiring that both the first and second mask portions include such an opening to permit access to phone features. (’291 Patent, col. 4:26-53).
- The complaint reserves the right to assert various dependent claims. (Compl. ¶¶25, 28, 31).
U.S. Patent No. 7,941,195 - "Protective Mask of Mobile Phone"
- Patent Identification: U.S. Patent No. 7,941,195, “Protective Mask of Mobile Phone,” issued May 10, 2011 (’195 Patent). (Compl. ¶3).
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’291 Patent, this patent addresses the identical problem of protecting delicate mobile phone housings from abrasion and providing a means for customization. (’195 Patent, col. 1:24-34).
- The Patented Solution: The solution is materially the same as in the parent ’291 Patent, describing a protective mask that sheathes a mobile phone. (’195 Patent, col. 2:30-33). Certain claims again focus on a two-part construction, while others are directed to a single-portion mask.
- Technical Importance: This patent continues the same inventive concept, securing claims that differ in scope, notably by including claims that do not require a second mask portion.
Key Claims at a Glance
- The complaint asserts independent claims 1, 6, and 9. (Compl. ¶36).
- Independent Claim 1: Structurally similar to claim 1 of the ’291 Patent, reciting a protective mask with a "first mask portion" and a "second mask portion", both adapted to be coupled to and retained on the phone's housing. (’195 Patent, col. 3:27-48).
- Independent Claim 6: Similar to claim 6 of the ’291 Patent, reciting the two-portion mask where the first portion includes an "opening" for access to a phone feature. (’195 Patent, col. 4:4-25).
- Independent Claim 9: This claim differs significantly, reciting a protective mask comprising only a "first mask portion" that has "flanges to allow the first mask portion to be coupled to the mobile phone to retain the first mask portion". This claim does not require a second mask portion. (’195 Patent, col. 4:32-41).
- The complaint reserves the right to assert various dependent claims. (Compl. ¶¶39, 42, 45).
U.S. Patent No. 10,097,676 - "Protective Mask of Mobile Phone"
- Patent Identification: U.S. Patent No. 10,097,676, “Protective Mask of Mobile Phone,” issued October 9, 2018 (’676 Patent). (Compl. ¶3).
The Invention Explained
- Continuing the same patent family, the ’676 Patent describes a protective mask for a mobile communication device that is "molded for frictional retention." (’676 Patent, Abstract). The invention focuses on an "integrally-formed mask body" whose inner surface maintains "substantially continuous surface-to-surface contact" with the phone's exterior and uses "at least one retainer having an extension protruding laterally inward" to help secure the mask to the device. (’676 Patent, col. 3:32-63).
Key Claims and Accused Features
- Asserted Claims: Independent claims 1, 5, 8, and 9. (Compl. ¶50).
- Accused Features: The infringement allegations for the ’676 patent target the accused products' integrally-formed bodies, frictional fit, conforming inner surfaces, and inward-protruding retaining edges or lips, which are alleged to function as the claimed "retainer." (Compl. ¶¶52, 55, 58, 60).
III. The Accused Instrumentality
Product Identification
The complaint identifies a wide range of Defendant’s protective masks for mobile devices, including phones and tablets, as the "Accused Products." (Compl. ¶¶13-14). The complaint distinguishes a subset of these as "Two Portion Accused Products," which consist of two separate pieces. (Compl. ¶16).
Functionality and Market Context
The Accused Products are cases designed to be coupled to mobile devices to provide protection from damage. (Compl. ¶18). The complaint alleges that these products secure the mobile device using a "flange or retainer." (Compl. ¶18). A product image for the "GOOSPERY Z Bumper Crossbody Case" shows a two-piece case for an iPhone. (Compl. p. 8). Another image provides a close-up of a corner feature on a two-piece case, highlighted by a red circle, which Plaintiff appears to identify as an infringing "flange." (Compl. p. 9). The complaint also includes images for the "Crystal Clear Bumper Case," a single-piece product, with a red circle highlighting the raised corner edge, presumably identifying it as the infringing "retainer." (Compl. p. 10). Defendant is alleged to sell these products for a vast number of device models from major manufacturers across its own websites and through major retailers like Amazon and Walmart. (Compl. ¶¶7, 15).
IV. Analysis of Infringement Allegations
'291 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| first mask portion, molded to conform to the shape of a first portion of the exterior housing of the mobile phone, the first mask portion having flanges to couple the first mask portion to the exterior housing of the mobile phone to retain the first mask portion to the first portion... | The Two Portion Accused Products allegedly include a first mask portion molded to conform to the phone's housing, which has flanges to couple and retain that portion to the phone. | ¶24a | col. 3:26-31 |
| a second mask portion, molded to conform to the shape of a second portion of the exterior housing of the mobile phone, the second mask portion adapted to be coupled to the mobile phone to retain the second mask portion to the second portion of the exterior housing... | The Two Portion Accused Products allegedly include a second mask portion molded to conform to the phone's housing, which is adapted to be coupled to and retained on the phone. | ¶24b | col. 3:33-39 |
| wherein said first and second mask portions are retained to the exterior housing of the mobile phone. | The first and second mask portions of the Two Portion Accused Products are allegedly retained to the exterior housing of the phone. | ¶24c | col. 3:40-41 |
- Identified Points of Contention:
- Scope Questions: A primary dispute may concern whether the retaining features of the accused two-piece products (e.g., for foldable phones) constitute "flanges" as that term is used in the patent. The patent figures depict discrete, hook-like structures, and the court may need to decide if the snap-on features of modern cases fall within that scope.
- Technical Questions: What evidence does the complaint provide that the accused features "couple" the mask to the phone in the manner described by the patent? The complaint's visual evidence highlights corner structures, raising the question of whether these perform the specific coupling and retaining function of the claimed "flanges." (Compl. p. 9).
'195 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first mask portion, molded to conform to the shape of a first portion of the exterior housing of the mobile phone | All Accused Products allegedly include a first mask portion molded to conform to the shape of a first portion of the phone's exterior housing. | ¶44a | col. 4:32-34 |
| the first mask portion having flanges to allow the first mask portion to be coupled to the mobile phone to retain the first mask portion to the first portion of the exterior housing... | All Accused Products allegedly have a first mask portion with flanges that allow it to be coupled to and retained on the exterior housing of the mobile phone. | ¶44b | col. 4:35-39 |
- Identified Points of Contention:
- Scope Questions: The central issue for this patent will be the construction of "flanges" as applied to single-piece cases. Does the continuous raised lip or edge common on modern flexible cases, which provides a friction fit around the screen, meet the definition of "flanges" as disclosed in the patent family?
- Technical Questions: The patent's specification and figures describe "a plurality of flanges" that appear to be discrete mechanical elements. (’291 Patent, col. 2:40-41; Fig. 3). A key question will be whether the single, continuous lip on the accused single-piece products is structurally and functionally equivalent to the plural, discrete "flanges" of the invention's embodiment.
V. Key Claim Terms for Construction
- The Term: "flanges" (’291 Patent, Claim 1; ’195 Patent, Claim 9)
- Context and Importance: The definition of this term is dispositive for nearly all infringement allegations. A narrow construction, limited to the discrete, hook-like structures shown in the patent figures, may support a finding of non-infringement for modern cases with continuous retaining lips. A broader, more functional definition could bring a vast array of modern phone cases within the claims' scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims require flanges "to couple" and "to retain" the mask portion. (’291 Patent, col. 3:28-30). Plaintiff may argue that any projecting edge that performs this function meets the claim's requirements, and the specification does not contain an explicit definition that would narrow the term's plain meaning.
- Evidence for a Narrower Interpretation: The specification describes and depicts "a plurality of flanges 21" which are shown as distinct, separate structures designed to engage "the edge of the front phone housing." (’291 Patent, col. 2:40-43; Fig. 3). A defendant may argue that this disclosure limits the term "flanges" to such discrete, plural elements, as opposed to a single, continuous, integrally molded lip.
- The Term: "retainer" (’676 Patent, Claim 1)
- Context and Importance: This term, introduced in the later ’676 Patent, appears to be Plaintiff's basis for accusing modern, single-piece, friction-fit cases. Its construction, and its relationship to the term "flanges" from the earlier patents, will be a central issue. Practitioners may focus on this term because it represents the patentee's attempt to adapt the original invention to evolving case technology.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim defines a retainer functionally as "having an extension protruding laterally inward from the integrally-formed mask body" that "participat[es] in retaining" the mask. (’676 Patent, col. 3:55-63). This broad, functional language may support an interpretation that covers the raised screen-side lip of a typical modern phone case.
- Evidence for a Narrower Interpretation: A defendant could argue that, within the context of the patent family, the term "retainer" should be understood as an evolution of the originally disclosed "flanges" and not as a complete departure. They may point to the shared specification and figures to argue that "retainer" still requires a more distinct structure than a simple contoured edge inherent to any friction-fit case.
VI. Other Allegations
- Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, it alleges that Defendant had pre-suit knowledge of all three asserted patents and their likely infringement as of July 24, 2024, based on email correspondence sent to Defendant's President and CEO. (Compl. ¶¶33, 47, 63). These allegations lay the factual groundwork for a potential future claim of willful infringement for any infringing acts that occurred after this date.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "flanges," disclosed in the patent family with reference to discrete, hook-like elements for early 2000s phone models, be construed broadly enough to cover the continuous, integrally molded retaining lips of modern smartphone cases?
- A related question will be one of technological evolution: does the later-patented term "retainer" successfully capture the design of modern friction-fit cases, or is it limited by the specification's original disclosure of a mechanically-coupled mask? The case may turn on whether the accused products represent a distinct, non-infringing technological path or merely an updated version of the patented invention.
- Finally, as this is a damages-only case for expired patents, a central battle will be over the value of the invention: what is the reasonable royalty for this patented technology in the highly crowded and price-sensitive market for third-party mobile device accessories?